Dennis Katz, D.D.S., P.C. - Page 8

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          disregarded because it was an agent of the shareholder or it did            
          not perform the services or otherwise conduct business.  See,               
          e.g., Commissioner v. Bollinger, 485 U.S. 340 (1988); Roubik v.             
          Commissioner, 53 T.C. 365 (1969).  Petitioner relies on these               
          lines of cases.  In other words, vis-�-vis Dr. Katz, the                    
          corporation should not be regarded as having a separate                     
               In Bollinger, the taxpayer formed a corporation with which             
          he entered into a written agreement that the corporation would              
          hold title to certain improved property as the taxpayer’s “agent            
          for the sole purpose of securing financing”.  Commissioner v.               
          Bollinger, supra at 342.  The corporation would convey the                  
          property on demand and had no obligation to maintain the property           
          nor to perform any functions with respect to the management of              
          the property.  The taxpayer performed all functions with respect            
          to the property.  On his tax return, the taxpayer claimed                   
          deductions relating to the property.  The Government disallowed             
          the deductions contending that the property belonged to the                 
          corporation and under Moline Properties, Inc. v. Commissioner,              
          supra,  the deductions were attributable to the corporation.  The           
          Supreme Court disagreed and held that on these facts the                    
          corporation was an agent of the taxpayer.                                   
               The relevant facts in Roubik were summarized by the Court in           
          its opinion, as follows:                                                    

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